Feed Materials Production Center Subcontractor 

Bioassay Results (1983-87) and 

Search Results for Scopes of Work (1984-85) 

Response Paper 

Rev. 0 

National Institute for Occupational 

Safety and Health 

August 21, 2014 

E.W. Potter 

Oak Ridge Associated Universities Team
 

-

Reviewed by Stuart L. Hinnefeld and Mark R. Rolfes 

Division of Compensation Analysis and Support
 

Page 1 of 9 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

Feed Materials Production Center Subcontractor Bioassay Results (1983-87) and Search Results for Scopes of Work (1984-85) 

BACKGROUND 

The issue of subcontractor bioassay sampling for uranium has been examined by NIOSH and the 

Advisory Board on Radiation and Worker Health’s (Advisory Board) Feed Materials Production 

Center (Fernald) Working Group (WG) over a period of several years. At Fernald, the reason for 

the bioassay sample was coded with a two-digit “sample type.” The sample type was either 

computer-generated or handwritten on the bioassay cards. The same code was input into a 

bioassay results table in a database. The HIS-20 database was the final database used at the site 

for this purpose. Over the years, over 40 different codes were used; but for the purposes of this 

analysis, only a few need explanation: 

	 Type 50 (also 5C, etc.) were non-routine samples. Type 50 is central to this analysis because 

it was used for nearly all subcontractor results, and thus, provides a means of identifying this 

class of workers. Type 50 was also used for “special” samples from site employees (e.g., 

taken after a change in process or procedures). For subcontractors, Type 50 bioassay cards 

frequently (but not always) had a company name written in the upper-right-hand corner. 

	 Type 20 were annual samples that generally applied only to site employees. 

	 Type 30 were routine samples that generally applied only to site employees. 

	 Type 10 samples were pre-hire bioassays and are generally excluded from analyses of site 

exposures. 

During the Verification and Validation (V&V) of the HIS-20 database against the hardcopy 

records, NIOSH determined that subcontractor bioassay results were not included in HIS-20 until 

late 1985. Because the Fernald co-worker approach for internal uranium exposure was based on 

the HIS-20 bioassay data, the WG consequently considered whether a set of data from 

exclusively prime contractor employees would provide an appropriate bounding exposure 

estimate for subcontractor employees. 

Extensive additional data capture yielded subcontractor bioassay results for the years 1969, 1971, 

1972, 1973, 1981, 1983, 1984, and 1985. NIOSH and the WG could not determine whether the 

lack of data for missing years, and the limited data for available years, was because: (1) 

subcontractor employees did not perform radiological work; or (2) because there were lax 

radiological controls for subcontractor employees. 

The argument for lax controls was that National Lead of Ohio (NLO), the operating contractor, 

did not carefully evaluate and control subcontractor exposures because they were expected to be 

Page 2 of 9 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

Feed Materials Production Center Subcontractor Bioassay Results (1983-87) and Search Results for Scopes of Work (1984-85) 

on site a short time, and therefore, would not exceed exposure limits during their stay. In one 

instance of subcontractor work, for which there is a reasonable work description and bioassay 

data, the co-worker approach did not bound the exposures of a few contractor employees. 

NIOSH concluded that there were not enough subcontractor bioassay samples for the years 1969, 

1971, 1972, 1973, and 1981 to generate a subcontractor-specific co-worker approach for those 

years, but proposed that there were enough subcontractor bioassay samples for a subcontractorspecific co-worker approach for 1983-1985. 

SPECIAL EXPOSURE CLASS RECOMMENDATION FOR SUBCONTRACTORS 

During the June 17, 2013, Fernald WG meeting in Cincinnati, Ohio, participants discussed 

potential dates for a subcontractor Special Exposure Cohort (SEC) class. After an exhaustive 

discussion, 1983 was recommended as the last year of inclusion. Sanford Cohen &Associates’ 

(SC&A) opinion was that 1983 was a “transition” year with most of the subcontractor samples 

grouped near the end of the year; thus, they were not representative of the entire year. SC&A 

also said, “Certainly '84 and '85 are, for all intents and purposes, indistinguishable from '86 in 

terms of the number of personnel and in the samples per person” (WG transcript, p. 51). NIOSH 

stated that there were sufficient data to construct a subcontractor co-worker study for 1984 and 

1985, if desired, but that the results for 1985 were statistically indistinguishable from the results 

used to develop the site-wide co-worker study. SC&A agreed that there were sufficient 

subcontractor bioassay samples to construct a separate co-worker study for 1984 and 1985 (p. 

157 of transcript). The WG Chairman and the WG agreed. At the Advisory Board meeting on 

7/1/2013, the following motion was passed, “add to the SEC all employees of subcontractors 

who worked at the Feed Materials Production Center in Fernald, Ohio, from January 1st, 1951 

through December 31st, 1983.” 

LETTER FROM FORMER SUBCONTRACTOR 

In March 2014, a letter was received from a former Fernald subcontract worker, suggesting that 

the SEC for subcontractors should be extended from 1983 to 1985, the last two years of site 

management by National Lead of Ohio (NLO). The main points of the letter are listed below 

along with NIOSH comments. 

1.	 Construction workers were brought in to do the work that “the house union could not do or 

did not want.” 

Page 3 of 9 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

Feed Materials Production Center Subcontractor Bioassay Results (1983-87) and Search Results for Scopes of Work (1984-85) 

NIOSH Comment: The letter was written from the perspective of a construction worker. The 

population added to the SEC through 1983 was all Fernald “subcontractors.” 

2.	 This work was all over the plant. 

NIOSH Comment: The statement that the work was all over the plant is true when applied to 

the entire population of subcontractors. However, this statement is not necessarily true for 

individual subcontractor- companies. 

3.	 During the NLO days, there were no work permits, no air monitoring, and no coverage by 

health and safety. 

NIOSH Comment: The author alleges problems with the site’s radiation protection programs, 

some or all of which may have been true for individual jobs. However, the bioassay program 

at Fernald was extensive. As the data presented below will show, 279 and 307 results were 

captured for subcontractors in 1984 and 1985, respectively. 

4.	 Most if not all of the bioassay testing in 1984 and 1985 were “Type 50 year end samples.” 

NIOSH Comment: As an illustration of his assertion regarding Type 50 year-end samples, 

the author attached his own bioassay results for 1984 and 1985. However, these were not his 

only samples during that time period. A separate analysis (“Monthly results&individuals 

1983-1985.doc”) shows that hardcopy bioassay results are available throughout these two 

years for subcontractors. It is true that there was less sampling in the colder months, which is 

consistent with a seasonal decrease in outdoor construction work. 

5. The actual date of the Plant 9 release was 12/14/1984. 

NIOSH Comment: The Plant 9 release date refers to the WG meeting on 6/17/2013 where 

there was speculation that the dust release from Plant 9 may have been the reason for 

increased sampling in late 1983. This is a moot point since 1983 is included in the SEC. 

On 4/15/14, the letter was discussed at a WG meeting. During this meeting, SC&A noted that, 

although there were enough subcontractor bioassay samples to generate a co-worker model for 

1984-1985, almost all the bioassay data were from employees of two subcontractor companies. 

In summary, they questioned: (1) why more of the 50 or so subcontractor companies apparently 

working on site were not represented in the hardcopy bioassay results; (2) why there were more 

samples in one-half of the year than the other; and (3) why there were in vivo results for Mobil 

Chemical. The last item was readily answered because Mobil Chemical was a neighboring 

facility with well contamination, not a subcontractor working on site. SC&A also gave an 

example of an incident in late July 1984 in which Langdon Hughes and Johnson Controls 

Page 4 of 9 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

 

 

 

 

 

Feed Materials Production Center Subcontractor Bioassay Results (1983-87) and Search Results for Scopes of Work (1984-85) 

workers were exposed on the roof over the re-melting area; however, these workers were 

monitored. As a result of this discussion, NIOSH agreed to investigate whether information was 

available on the scopes of work that the subcontractors were performing. 

SUBCONTRACTOR BIOASSAY RESULTS 

On a call between DCAS and the ORAUT on 4/18/14, the percentages of Fernald subcontractor 

results and individuals for 1983-1986 were presented in a table. One action item from the call 

was to also analyze the 1987 subcontractor results. These results were hand-entered into a 

workbook from the bioassay cards in SRDB 92450 and 92453. The workbook, which also 

contains the earlier work, was renamed “Subcontractor data 7-11-14.” The data presented on 

4/18/14 for 1985 were adjusted because there were some contractor results for December 1985 

that were included in HIS-20. The updated results are presented in Table 1 on this page. The 

“Percentages” shown in the table represent the fraction of site population represented by the 

subcontractors. 

Table 1: Urine Results and Individuals Monitored by Year 

Year Site Subcontractors Percentages 

Results Individuals Results Individuals Results Individuals 

1983 3545 1015 164 38 4.6% 3.7% 

1984 4235 1060 279 82 6.5% 7.7% 

1985 8098 1003 307 67 3.8% 6.7% 

1986 9826 1577 370 79 3.8% 5.0% 

1987 9226 1686 580 85 6.3% 5.0% 

Notes on Site column totals:
 

 1983-1984: HIS-20 plus subs from hardcopy
 

 1985: HIS-20 plus subs from hardcopy minus subs in HIS-20 

 1986-1987: HIS-20 only
 

 Notes on Subcontractor column totals: All results were only those identified in hardcopy less Type 10
 

The last names and initials on the bioassay cards provide a means of matching the bioassay cards 

to HIS-20; this was done for 1987. In HIS-20, there were 583 results located for 81 individuals. 

There were four suspected subcontractors with bioassay results that were not located in HIS-20. 

They are shown below in Table 2 on the next page. Some results were probably missed in 

hardcopy since not all subcontractor cards had a subcontractor name written on them. The 

Page 5 of 9 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

 

 

Feed Materials Production Center Subcontractor Bioassay Results (1983-87) and Search Results for Scopes of Work (1984-85) 

differences between HIS-20 and hardcopy represent less than 5% for both results and 

individuals. 

Table 2: 1987 Data Located in Cards But Not in HIS-20 

Name Company Results Comments 

[Name redacted] Unknown 6 Type 50s; “50” in badge No. 

[Name redacted] Unknown 2 Type 50s; “50” in badge No. 

[Name redacted] Rust 2 Rust or "Sub" on card 

[Name redacted] Unknown 13 Type 50s; “50” in badge No. 

The annual breakdowns by subcontractor companies based on the hardcopy results are shown in 

Tables 3 and 4 on this page and tables 5 through 7 on page 7. The number of individuals will not 

necessarily add up to the values in Table 1 because some individuals had more than one 

company listed on their bioassay cards in a given year. 

Table 3: Urine Results and Individuals Monitored 1983 

Company Results Individuals 

Hughes 1 1 

Legge 158 33 

Richter Construction 5 5 

Total 164 39 

Table 4: Urine Results and Individuals Monitored 1984 

Company Results Individuals 

Hamilton County 3 3 

Johnson Controls 2 2 

Kirk & Bloom 5 3 

Langdon, Inc. 6 4 

Legge 137 28 

Quality Scale 1 1 

Rust 121 43 

Wm. Kramer & Son 2 2 

Unknown 2 2 

Total 279 88 

Page 6 of 9 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

Feed Materials Production Center Subcontractor Bioassay Results (1983-87) and Search Results for Scopes of Work (1984-85) 

Table 5: Urine Results and Individuals Monitored 1985 

Company Results Individuals 

Cincinnati Bell 1 1 

Martin Marietta 2 2 

Meco Electric 3 2 

Rust 295 59 

Suspected Rust 2 2 

Unknown 4 4 

Total 307 70 

Table 6: Urine Results and Individuals Monitored 1986 

Company Results Individuals 

Cincinnati Crane 2 2 

Fenton Rigging 3 3 

Langdon, Inc. 1 1 

Rust 357 71 

Unknown 7 6 

Total 370 83 

Table 7: Urine Results and Individuals Monitored 1987 

Company Results Individuals 

Ferguson 6 1 

Hittman Nuclear* 24 3 

Langdon, Inc. 9 4 

Rust 439 53 

Unknown** 102 28 

Total 580 89 

* Apparently a contractor for the supercompactor. Some cards show both Hittman and Rust. 

** Names were compared to names with 1983-1986 results, but no company could be identified. 

PLANT 9-RELATED IN VIVO COUNTS 

In early 1985, a number of subcontractors as well as members of the public and employees of a 

neighboring facility were in-vivo-counted as a result of the Plant 9 release referred to above. The 

data for the subs and Mobil Chemical appear in Table 8 on the next page. These data show that 

employees from 12 subcontractor companies were monitored in 1985, in addition to the ones 

shown in Table 5 on page 6. 

Page 7 of 9 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

 

Feed Materials Production Center Subcontractor Bioassay Results (1983-87) and Search Results for Scopes of Work (1984-85) 

Table 8: In Vivo Counts, 1985 (SRDB 94407) 

Company Results Individuals 

Allegany Electric* 2 2 

Burke 1 1 

CG&E 18 18 

Cincinnati Bell 11 11 

Cincinnati Microwave 1 1 

ESI 1 1 

J&N Steel 3 3 

Kramer Roofing 16 16 

Little Hills 1 1 

Mobil Chemical** 33 32 

Motion Savers 1 1 

Nu-Pave, Inc. 4 4 

Quality Scale Sales 3 3 

Rust 48 44 

Saunders & Thomas 4 4 

Unknown Sub 2 2 

Total 149 141 

* Sub to Rust. ** Off-site group; not a subcontractor. 

SEARCH RESULTS FOR SUBCONTRACTORS’ SCOPES OF WORK 

In addition to the analysis of subcontractor bioassay presented above, NIOSH completed a search 

for data on subcontractors’ scopes of work for 1984-1985. A separate data capture trip was 

performed for this purpose. Sixty-three boxes of documents containing information on 

subcontractors were identified and reviewed. The review specifically looked for any type of 

information that would ensure that the work performed by subcontractors would be conducted in 

a manner that met site radiological safety standards in place at the time. Sixty-eight new 

documents were captured. Unfortunately, the site operator (NLO) did not keep subcontract 

documents beyond their retention dates. 

Most of the documents recovered were for 1986 and later. The most interesting document 

located included Job Access Request Forms for 1986 and 1987 (SRDB 133930). These forms 

sometimes included rudimentary descriptions of the purpose of the visit. These forms were 

compared to the 1984-1987 contracts in SRDB 99119 to determine if there was information on 

the type of work the companies typically performed. Unfortunately, there was little overlap 

between the access forms for 1986-1987 in SRDB 133930 and the contracts in SRDB 99119. 

Three companies were identified, but only two had contracts during 1984-1985. The remaining 

Page 8 of 9 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

Feed Materials Production Center Subcontractor Bioassay Results (1983-87) and Search Results for Scopes of Work (1984-85) 

one had a contract in 1986. All three of the companies performed construction or electrical work. 

However, the access forms were not sufficiently detailed to rule out work in areas that would 

have required bioassay samples. The following conclusions are consistent with the data: 

	 By 1984, there was a greater diversity of subcontractor companies being sampled. 

	 In 1984 and 1985, there are multiple results per individual for Legge and Rust. These 

companies were likely involved in the most hazardous and intrusive work. There is no reason 

to believe that there are unmonitored subcontractors who would have been more highly 

exposed. In 1985, a number of subcontractors have in vivo counts in addition to the subs 

monitored by urine samples. 

	 Even after 1985 and the end of the NLO tenure, one cannot identify dozens of subcontractors 

being sampled, as was speculated in the 4/15/14 WG Meeting. 

	 In 1987, there was at least one subcontractor to Rust brought in (see footnote for Table 7). 

Perhaps there were other secondary subcontractors who had “Rust” written on their cards; as 

a result, not every secondary subcontractor may have been directly identified by name on 

their cards. 

	 In 1987, number of subcontractors with no company name on the bioassay card (“unknown” 

category) increased from previous years. This could either be from an increased 

subcontractor sampling program or from a change in how the information was being 

recorded on the cards. 

	 The fact that the number of samples is increasing from 1984-1987 is as consistent with 

increased workload as it is with under-sampling in the earlier years. The number of 

subcontractors sampled remained relatively constant. 

	 There are enough individual samples for 1984 and 1985 to do a valid one-person, one-sample 

analysis. The fact that these samples were not evenly-distributed over the year is not a 

requirement and is, in fact, consistent with nature of most subcontract work. 

	 Subcontractor in vivo results from 1985 should not be considered indications of radiological 

subcontract work, because subcontractors (like members of the general public) were 

receiving in vivo exams upon request in response to the Plant 9 dust collector release. 

	 NIOSH was unsuccessful in locating information on the subcontractors’ scopes of work for 

1984-1985. 

Page 9 of 9 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.